Politique de confidentialité

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy applies to the personal data that We collect and process acknowledging and
understanding that Your privacy is important to You and that You care about how Your personal data is
collected and processed.

We are Limited Partnership and We are a company incorporated in the UK and registered office at 39/5
Granton Crescent, Edinburgh, EH51BH, UK.

We at Limited Partnership are dedicated to safeguarding and preserving Your personal data and privacy
when visiting Our Websites, utilising Our services, products or communicating electronically with Us.

For the purposes of the data protection laws that apply to us, including the GDPR which is the European
General Data Protection Regulation and UK Data Protection Law, We act as the Data Controller for the
personal data that We collect and process to enable You to make use of Our Services.

The purpose of this Privacy Policy is to transparently provide You with an explanation as to the legal
basis for Us collecting and processing Your personal data, the categories of personal data that We may
collect about you, what happens to the personal data that We may collect, where We process Your personal
data, how long We are required to retain Your personal data, who We may share Your personal data with
and to also explain Your rights as a data subject.

We do update this Privacy Policy from time to time and will post all updates to Our Website as and when
issued. Please do review this policy regularly on Our Website for any changes.

DEFINITIONS AND INTERPRETATIONS

In this Privacy Policy the following terms shall have the following meanings:

Cookie

means a small text file placed on Your computer or device by Our Websites when You visit certain
parts of Websites.

GDPR

means the General Data Protection Regulation (EU) 2016/679, of the European Parliament and of the
Council of 27 April 2016 on the protection of natural persons with regard to the processing of
Personal Data and on the free movement of such data, and repealing Directive 95/46/EC, as amended,
replaced or superseded and in force from time to time and as transposed into member-state
legislation.

Privacy Policy

means this Privacy Policy updated from time to time and made public on Our Websites.

Personal Data

means any information which relates to an identified or identifiable natural person. An identifiable
person is one who can be identified directly or indirectly in particular by reference to an
identifier such as a name, an identification number, location data, an online identifier or to one
or more factors specific to the physical, physiological, genetic, mental, economic, cultural or
social identity of that natural person.

Website

means the website, which is owned by the Company.

Services

mean all Our products: Website or other.

You, Your

You, as User or Guest, depending on your status at the Website.

We, us, our

refers to Limited Partnership.

YOUR DATA PROTECTION RIGHTS

Under the GDPR you, as a data subject, have certain rights over the personal data that We hold and
process.

At Limited Partnership, We are committed to make it easy for You to exercise these rights in the most
transparent manner possible. You can exercise any of Your rights in relation to the data that Limited
Partnership holds about you, by contacting Our data protection officer through the email address
provided at the end of this section or through Your personal user cabinet.

The following are the specific rights You have over Your personal data We hold and process, namely:

The right to be informed about Our collection and processing of Your personal data including
without limitation the legal basis for the collection and processing, the categories of data, the
methods of data use, the envisaged period for which the personal data will be retained. This Privacy
Policy should tell You everything You need to know, but You can always contact Us to find out more
or to ask any questions.

The right to access Your personal data We collect about you, commonly referred to as "Subject Access Requests" , which provides you, as the data subject, the right to obtain a copy of Your personal data that
We are processing for You

Pursuant to GDPR We are required to respond without undue delay to all Subject Access Requests in
practice this means We have to respond within 1 month of receipt of the Subject Access Request.

Ordinarily Subject Access Requests are free of charge.

We may extend the time period for responding to a Subject Access Request by a further two months and may
charge a reasonable fee if We deem the request to be manifestly unfounded or excessive, however, We are
required to advise You of Our intention to do this within 1 month of Your subject access request.

Should You wish to make a Subject Access Request this can be done by contacting the Company using the
contact details in Section 9.

The right to have Your personal data rectified
if any of Your personal data that We collect and process is in any way inaccurate or incomplete.

The right of erasure (otherwise known as “the right to be forgotten”), i.e. the right to ask
Us to delete or otherwise dispose of any of Your personal data that We process. Please note that
this is not an absolute right and We may not be able to comply with Your request as We may be
legally obliged to continue to retain Your personal data for a specific period

The right to restrict (i.e. prevent) the processing of Your personal data by us.

The right to object to Us processing Your personal data for a particular purpose or purposes.
Please note that the right to object only applies in certain circumstances and will depend on the
purposes or legal basis for the processing.

The right to data portability. This only applies where You have provided personal data to Us
directly, the legal basis for Us processing Your personal data is i) consent or ii) for the
performance of a contract and We are processing Your data using automated means. In such instances
You have the right to receive Your personal data (or request that We transfer it to another
Controller) in a structured, commonly used and machine readable format.

Rights relating to automated decision-making and profiling. We do not use Your personal data
in this way.

The right to lodge a complaint with any relevant Data Protection Authority, in particular in
the member State of Your residence, place of work or the place of processing Your personal data.

Data Subject Request

Timescale

The right to be informed

When data is collected

The right of access

2 weeks

The right to rectification

2 weeks

The right to erasure

Without undue delay

The right to restrict processing

Without undue delay

The right to data portability

2 weeks

The right to object

On receipt of objection

Rights in relation to automated decision making and profiling.

2 weeks

If You wish to exercise any of the aforementioned rights, please contact Us. We request that in
the first instance You contact Our data protection officer at any time Our on
help@skin.club

We promise to promptly consider Your request and to respond to You in accordance with the
requirements of the UK Data Protection Act and GDPR.

Complaints to the UK Data Protection Inspectorate should be made by using the appropriate forms
provided in the UK Data Protection Inspectorate Website.
https://ico.org.uk/make-a-complaint/

PERSONAL DATA WE COLLECT ABOUT YOU

PRINCIPLES OF PROCESSING

During collecting and processing the personal data, the Company adheres the principles as
follows:

Fairness – in order to process fairly, the controller has to make certain information
available to the data subjects as practicable. This applies whether the personal data
was obtained directly from the data subjects or from other sources.

Transparency – any information and communication relating to the processing of the
personal data be easily accessible and easy to understand, and that clear and plain
language be used.

Purpose limitation

The personal data must be collected for specified, explicit and legitimate purposes and
not further processed in a manner that is incompatible with those purposes; further
processing for archiving purposes in the public interest, scientific or historical
research purposes or statistical purposes shall, not be considered to be incompatible
with the initial purposes.

Data minimization

The personal data must be adequate, relevant and limited to what is necessary in
relation to the purposes for which they are processed.

Accuracy

The personal data must be accurate and, where necessary, kept up to date; every
reasonable step must be taken to ensure that personal data that are inaccurate, having
regard to the purposes for which they are processed, are erased or rectified without
delay.

Storage limitation

The personal data must be kept in a form which permits identification of data subjects
for no longer than is necessary for the purposes for which the personal data are
processed. Personal data may be stored for longer periods insofar as the personal data
will be processed solely for archiving purposes in the public interest, scientific or
historical research purposes or statistical purposes, if only are implemented
appropriate technical and organizational measures required by governing law in order to
safeguard the rights and freedoms of the data subject.

Integrity and confidentiality

The personal data must be processed in a manner that ensures appropriate security of the
personal data, including protection against unauthorized or unlawful processing and
against accidental loss, destruction or damage, using appropriate technical or
organizational measures.

LEGAL BASIS FOR COLLECTING AND PROCESSING PERSONAL DATA

Limited Partnership will process Your personal data based on legal bases such as:-

the performance of Our contract with You (i.e. the provision of Our Services to you);

our legitimate business interests (i.e. for fraud prevention, maintaining the security of
Our network and services, seeking to improve the Services that We provide and Your
interaction with us). Whenever We rely upon on this lawful basis We assess Our business
interests to make sure that they do not override Your rights. Furthermore, in some cases You
have the right to object to this processing;

with Your consent .for direct marketing purposes so that We may keep You fully up to date
with other products and services that We supply and think may be of interest to you. Where
We rely upon consent, We will need Your explicit consent, which may be removed at any time;

our legal obligation.

CATEGORIES OF THE PERSONAL DATA WE COLLECT

A summary of the Personal Data that We process, when We collect it, how We use it and why We use
it (i.e. the legal basis for processing) is listed below:

Personal Data

When We collect

How We use

Why We use

Steam ID, nickname, avatar

In registration procedure

We use Your personal and contact information to register You as a User and identify
You in Our Services. We use it to

Necessary for the performance of a contract with you

email

In registration procedure, in event registration

Use email to restore Your account. We use it to notify You about changes to Our
Terms or Privacy Policy; to communicate with you.

Necessary for the performance of a contract with you

Information about Your transactions

When You do the transaction

We use it for make transactions. All transactions are carried out using third-party
services

Necessary to comply with a legal obligation

Service id

When You use Our services

We use it to optimise Our service and to improve Our Website, services, direct
marketing, User relationships, behaviour profiling and experiences

Necessary for Our legitimate interests

PROTECTING YOUR PERSONAL DATA AND DATA RETENTION

We use, store and process Your personal data on Limited Partnership servers which are located on the
Netherlands.

By filling a “consent application” You agree to this conditions of collection, processing, transfer and
storing Your personal data. When We process Your personal data for one of the legal bases specified in
this Privacy Policy, We will take all steps reasonably necessary to ensure that Your Personal Data is
treated securely and in accordance with this Policy.

Limited Partnership protect Your Personal Data under internationally acknowledged standards, using
physical, technical, and administrative security measures to reduce the risks of loss, misuse,
unauthorized access, disclosure, and alteration. Some of the safeguards Limited Partnership use are
firewalls and data encryption, physical access controls to Our data centers, and information access
authorization controls. Limited Partnership also authorize access to Personal Data only for those
employees or contractors who require it to fulfill their job or service responsibilities. The Limited
Partnership’s staff is trained on procedures for the management of personal information, including
limitations on the release of information. Access to personal information is limited to those members of
Our staff and contractors whose work requires such access. Limited Partnership conducts periodic reviews
to ensure that proper information management policies and procedures are understood and followed. All of
Our physical, electronic, and procedural safeguards are designed to comply with applicable laws and
regulations.

HOW WE PROTECT YOUR DATA

When You provide Your personal data through Our Website, KYC portals, Our applications, this
information is transmitted across the internet securely using industry standard encryption. Your
personal data will be held encrypted on secure servers.

Where any third parties process Your personal data on Our behalf, We require that they have
appropriate technical and organizational measures in place to protect this personal data and We
will also ensure that a GDPR compliant. Data Processing Agreement is in place between Limited
Partnership and the third party so that both parties understand their responsibilities and
liabilities pursuant to GDPR.

HOW YOU CAN PROTECT YOUR PERSONAL DATA

When You create Your account, choose a strong password that is unique to this account. Do not
share Your password with other people. Using the same password across Your different accounts
will increase the risk of Your data being compromised if Your password is accidentally or
unlawfully accessed by unauthorized persons. If You suspect that someone else has got access to
Your password, make sure that You change it immediately. When using Our wallets, ensure You keep
Your passphrases and keys in a secure device isolated from devices You use regularly. Do not
share the device containing Your passphrases and keys with friends, family members or even
people You trust.

DATA RETENTION

Your personal data will be retained for as long as necessary to satisfy the purposes We received
it for, this includes regulatory and business purposes.

In determining the necessary personal data retention period, the following factors are
considered:

The amount of personal data as We aim to minimize this amount to the extent possible for
each specific purpose specified in Section 4.2 of this Privacy Policy.

The nature of the personal data depending on the exact purpose which this specific personal
data serves as detailed in Section 4.2 of this Privacy Policy.

The sensitivity of the personal data by its nature and substance.

The potential risk of harm from unauthorized use or disclosure of Your personal data and We
continue to run risk assessments and risk mitigation activities to minimize this potential
risk including engagement of third party specialized data management and data protection
providers.

The purposes for which We process Your personal data and whether We can achieve those
purposes through other means, and the applicable legal requirements.

THIRD PARTY LINKS

You may find links to third party Websites on Our Website or chats of users contained on Our Website or
mobile applications. These Websites should have their own privacy policies which You should check. We do
not accept any responsibility or liability for their policies whatsoever as We have no control over
them.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We do not share Your Personal Data to third Parties, except cases that are mentioned in this Privacy
Policy.

WITH YOUR CONSENT

We will share information with companies, organizations or individuals outside of Limited
Partnership when We have Your explicit consent.

TO COMPLY WITH THE LAW

We may share information in response to a request for information if We believe disclosure is in
accordance with, or required by, any applicable law, regulation, legal process or governmental
request, including, but not limited to, meeting national security or law enforcement
requirements. To the extent the law allows it, We will attempt to provide You with prior notice
before disclosing Your information in response to such a request.

IN AN EMERGENCY

We may share information if We believe that it's necessary to protect the vital interests of the
data subject (i.e. to prevent imminent serious physical harm or death to a person.)

TO ENFORCE OUR POLICIES AND RIGHTS

We may share information if We believe Your actions are inconsistent with Our user agreements,
rules, or other Limited Partnership policies, or to protect the rights, property, and safety of
ourselves and others.

WITH OUR AFFILIATES

We may share information between and among Limited Partnership and any of Our parents,
affiliates, subsidiaries, and other companies under common control and ownership.

WITH OUR PARTNERS

We may share information with vendors, consultants, and other service providers (but not with
advertisers and ad partners) who need access to such information to carry out processing
activities for us. The partner’s use of personal data will be subject to appropriate
confidentiality and security measures.

We may share Your private personal data with such service providers subject to obligations
consistent with this Privacy Policy and any other appropriate confidentiality and security
measures, and on the condition that the third parties use Your private personal data only on Our
behalf and pursuant to Our instructions.

We may share Your private personal data with our partners to make a transaction.

Where any third parties process Your personal data on Our behalf, We require that they have
appropriate technical and organizational measures in place to protect this personal data and We
will also ensure that a GDPR compliant. Data Processing Agreement is in place between Limited
Partnership and the third party so that both parties understand their responsibilities and
liabilities pursuant to GDPR.

INTERNATIONAL TRANSFERS OF PERSONAL DATA

GDPR applies to controllers and processors located in the European Economic Area (“the EEA) and
countries that the EU has deemed to provide adequate protection to data subjects from a data
protection perspective. UK is a country in EU and it has been recognised by the EU as being an
“adequate” country from a data protection perspective.

Data Subjects risk losing the protection of GDPR if personal data is transferred outside of i)
the EEA or ii) countries holding adequacy status and accordingly GDPR restricts such transfers,
unless the rights of data subjects in respect of their personal data is protected by appropriate
safeguards or one of a limited number of exceptions applies (such exceptions include Your
explicit and informed consent).

Limited Partnership will not make any international transfers of Your personal data to countries
outside the EEA (or a country holding adequacy status) unless it has i) Your explicit and
informed consent or ii) it has put in place the appropriate safeguards or iii) the international
transfer is covered by an exception.

ADVERTISING, ANALYTICS AND BUSINESS PARTNERS (LIMITED TO NON-PERSONALLY IDENTIFIABLE
INFORMATION)

We may share aggregated or pseudonymous information (including demographic information) with
partners, such as publishers, advertisers, measurement analytics, apps, or other companies. For
example, We may tell an advertiser how its ads performed or report how many people installed an
app after seeing a promotion. We do not share information that personally identifies You
(personally identifiable information is information like name or email address) with these
partners, such as publishers, advertisers, measurement analytics, apps, or other companies.

OTHER INFORMATION

Other information, that does not personally identify You as an individual is collected by
Limited Partnership (such as, by way of example, patterns of use) and is exclusively owned by
Limited Partnership. We can use this information in such manner that Limited Partnership, in its
sole discretion, deems appropriate.

We may share specific aggregated, non-personal information with third parties, such as the
number of users who have registered with us, the volume and pattern of traffic to and within the
site, etc. That information will not identify you, the individual, in any way.

We shall not use Your email or other contact information for sending of commercial proposal,
other marketing needs, without Your prior consent.

In the light of the above, when You send Us messages, We can keep them for administering of Your
inquiries, for improving of Our services. We shall not transfer information from such messages
to third parties.

USE OF COOKIES

To enhance the quality of Our services, provide You with relevant content as well as understanding how
You use Our Website and applications, We use technologies, such as Cookies. Cookies do not typically
contain any information that personally identifies you, but personal information that We store about You
may be linked to the information stored in and obtained from Cookies.

We use Strictly Necessary Cookies - these are required for the operation of Our Website. They include
User session key, browser language. This is a temporary key issued to the User after the successful
logging in. This cookies are used to enable You to log into secure areas of Our Website.

CONTACTING US

We welcome any queries, comments or requests You may have regarding this Privacy Policy. If You wish to
make a subject access request, please do not hesitate to contact Us at 39/5 Granton Crescent, Edinburgh,
EH51BH, UK help@skin.club

CHANGES TO THIS PRIVACY POLICY

Any changes that We make to Our Privacy Policy in the future will be posted on Our Website. Where
appropriate, We will notify You of the changes when You next visit Our Website. This Privacy Policy was
last updated on January 29th 2020.